The revised notice provides clarity for multinational enterprises, confirming which jurisdictions’ Pillar Two rules the UK recognises for IIRs and top-up tax compliance.

UK’s Tax Authority, HM Revenue & Customs (HMRC) has issued an updated notice specifying jurisdictions with a qualified income inclusion rule (IIR) and/or a qualifying domestic top-up tax (QDMTT) that meets safe harbour standards.

The revised notice provides clarity for multinational enterprises, confirming which jurisdictions’ Pillar Two rules the UK recognises for IIRs and top-up tax compliance.

The update follows changes to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), reflected in its central record of jurisdictions.